Britain’s former Prime Minister, Boris Johnson, has been compared to America’s Donald Trump. The two are certainly populists and utilise similar language now that they are facing repercussions for their actions. Neither is particularly fussy about ensuring that anything they say corresponds to the truth, and at a personality level both have been described as narcissists who are ultimately concerned with what is in their own interest, rather than that of the nations which they have led. In short, they lack personal integrity.
What distinguishes them in terms of the damage they can inflict is the systems in which they operate. The former President, facing serious federal criminal charges, is nevertheless the leading contender for the Republican nomination for the presidency and should he secure it, has a very real chance of becoming President again. There is nothing in the US Constitution to say that if, for example, he were in jail he would be debarred from campaigning for the presidency and appearing on the ballot. This has become possible because neither the founding fathers nor the legislators who subsequently added amendments to the Constitution thought it was even remotely likely that someone charged with a criminal offence, let alone convicted of one, could aspire to the presidency.
The US, of course, has a presidential system whereby the president is separately elected and does not sit in the Senate or the House, However, America has an extremely robust and extensive Congressional committee system which considers Bills, conducts investigations and begins the confirmation process for various presidential appointments. The powers of committees are really quite substantial and include the ability to issue subpoenas for officials, experts and citizens to appear before them should that become necessary. As things stand the committee system represents a powerful tool for implementing accountability.
For all of that, barring impeachment in the Senate, Congress has no means of holding a president to account, and Mr Trump survived two impeachments during his term of office. As such, even although he attempted to overturn the American democratic process following the 2020 election and has now been criminally indicted over his retention of secret documents, the legislature cannot prevent him from running for president.
In the case of the UK voters elect a party, not a prime minister, although there have been times – and the 2019 election is probably a case in point – where the prime ministerial candidate might give a party its lustre, thereby attracting voters it might not otherwise have had. Supporters of Mr Boris Johnson never tire of alluding to the fact that he was the one who gave the Conservative Party its remarkable 80 seat majority in the last election. The difference with the United States is that even during a term in office, a party can dismiss a prime minister, as indeed the Tories did in the case of Mr Johnson. The House of Commons does have the power of impeachment, but it hasn’t been used since the 19th century.
The most important difference with the United States, however, lies in the fact that a prime minister is answerable to MPs in Parliament, and while he or she can be asked questions on specific issues under discussion when present at any time, s/he must make themselves available every Wednesday afternoon to answer members’ questions. It is known as Prime Minister’s Question Time. And what a prime minister or a minister has to say in Parliament has to be truthful. And Mr Johnson was repeatedly untruthful when he answered questions about what has become known as ‘partygate’ in No. 10.
The consequence of his false statements was that the House of Commons set up a Privileges Committee, chaired by a Labour MP but consisting of a majority of Conservative members to investigate whether he did so deliberately. The committee issued a damning report saying he had done so multiple times, and recommended a sanction which if Parliament approved the report would have involved a by-election in Mr Johnson’s constituency. The former Prime Minister, who had a preview of the findings, did not wait for the House of Commons vote, but resigned, calling it a “witch-hunt” and deeming the Privileges Committee a “kangaroo court”.
On Monday the House of Commons held a vote on the report in any case which saw 354 members vote in favour of whom 118 were Tories, and 7 against. It must be said that 225 MPs did not vote at all, many probably because they did not want to be publicly identified with one side or the other, particularly if their personal views conflicted with those of their constituency parties. Mr Johnson’s supporters had been asked by him not to vote, because, said commentators, it would have revealed how weak his support among Tory MPs was.
Those who voted in favour, including former Tory Prime Minister Theresa May, were very clear about their reasons. Not to tell the truth in Parliament was to abandon accountability and undermine democracy. Speaking during the Commons debate prior to the vote, she said backing the report would be “a small but important step in restoring people’s trust” in Parliament. It was “important to show the public that there is not one rule for them and another for us”, she said.
As in the US with Mr Trump, Mr Johnson has his vocal supporters, both within the Commons and outside it. The difference is that the number of Conservatives in the House who are prepared to defend a former leader who subverted democracy was in a minority, as opposed to the situation in the Republican Party in a case where the assault on democracy was far more serious.
In circumstances where we may be looking at constitutional reform in the not-too-distant future, what goes on in democracies, one of which is the source of our own political institutions, and the other of which until recent times was held to be an example to democracies everywhere, is a matter of relevance. We have a parliamentary democracy, although not a very robust one, since Parliament among other things meets but infrequently nowadays. There was an excuse for that during Covid, but no longer.
In addition, of course, most parliamentarians regard being an MP as a secondary job, having employment elsewhere, and there are no resources for them within the parliamentary context such as research aides to provide professional quality information on an issue or a Bill. There are Select Committees to which Bills can be referred for examination, but they lack the powers of their US counterparts, and the governing party has been in the habit of bypassing these even in the case of important and controversial legislation. That party has also been treating the long established Public Accounts Committee, a Standing Committee, with contempt by failing to ensure that enough of its members are present for a quorum on a regular basis. And this is the committee which has a critical role in ensuring accountability in the public finances.
We have a hybrid system, of course. There is an executive president but he or she is selected by the party which wins the national vote; there is no separate election as in the US. Nevertheless, once in office a party cannot remove a president Boris Johnson style, and he or she does not sit in Parliament so is not answerable there as a prime minister would be. In fact, if he or she so chooses, they would not have to answer questions anywhere, and President Irfaan Ali avoids them for the most part by not holding press conferences.
As to whether either of our main parties would operate as the Tory party has done in the face of wrongdoing in the House on the part of one of its members, the answer is no; the list system sees to that. There are complexities in the Guyanese situation which do not apply in the large democracies, involving ethnically based parties which put loyalty above other considerations. This makes it possible for them to accept attempts at vote-rigging in the case of one, and various other ethical failings in the case of both, unless they are under greater than usual external pressure to take action in relation to one of their officials.
In general, however, reforming the system to make our parliamentarians more accountable in all ways will be a challenge, and will require careful thought.
